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TMI Blog2017 (5) TMI 1788X X X X Extracts X X X X X X X X Extracts X X X X ..... tuation for the assessment years 2004-05 and 2005-06 [ 2016 (4) TMI 1427 - ITAT MUMBAI] and directed that 2% of the dividend income be disallowed as expenses attributable for earning dividend income u/s 14A Following the said order, we direct the Assessing Officer to compute the disallowance at 2% of the exempt income during this assessment year also u/s 14A of the Act. Appeal of the Assessee ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d. 3. Coming to the disallowance made by the Assessing Officer u/s 14A, the Ld. Counsel for the Assessee submits that assessment year being 2006-07, the provisions of Rule 8D have no application. The Ld. Counsel submits that Assessing Officer disallowed expenses attributable for earning dividend income by invoking Rule 8D r.w.s 14A which was sustained by the Dispute Resolution Panel-II. The Ld. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sment years, 2% of such exempt income may be directed to be disallowed u/s 14A of the Act. 4. The Ld. DR vehemently supported the orders of the authorities below. 5. We have heard both the parties, perused the order of this Tribunal in Assessee s own case for earlier assessment years. The Coordinate Bench considered similar situation for the assessment years 2004-05 and 2005-06 and directed ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... R) also conceded that of reasonable disallowance on this issue can be made and requested for estimation of disallowance of 2%. On this, the Id. Counsel for the assessee very fairly agreed for the same. In view of the above concession given by both the parties, we direct the A.O. to recompute the disallowance by estimating at 2% of the exempt income. The A.O. is directed accordingly. 6. Followi ..... X X X X Extracts X X X X X X X X Extracts X X X X
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